An employee who works in a business on a full-time basis (ie more than an average of 20 hours per week) for five or more years will not be subject to TOSI even where the years occurred before the TOSI rules came into effect and even where the employee was not related to the source individual at the time the work was done. CRA technical interpretation 2018-0783741E5, February 27, 2019. Georgina Tollstam “Five-Year Test in TOSI’s ‘Excluded Business’ Definition” Canadian Tax Highlights 27:6 (June 2019)
